Last Updated on Feb 18, 2019
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Inoven A.S. Resitpasa Mah. Katar Cad. ITU Teknokent Ari4 Magnet, Maslak, Sariyer, Istanbul / TURKEY
1. What Personal Information Do We Gather About You?
When you use Cognity, your test answers and drawings are processed by our cloud servers.Cognity mobile app send all of these inputs via SSL layer without keeping any personal identification data except IP address and age. Inoven keeps the test results and drawings for improving the test accuracy and developing new methods without keeping any personal identification data except IP address and age. You can also get yout test results and request to receive marketing related messages to your e-mail address optionally by providing your e-mail address at the end of the test
2. What Do We Do With The Personal Information We Collect About You?
We collect, use or otherwise process personal information as allowed under applicable law, including where based on one or more of the following:
- The consent you provide to us at the point of collection of your personal information;
- The compliance of a legal obligation to which we are subject; or
- The legitimate interests of Inoven, a third party or yourself. "Legitimate interest" is a technical term under the regulation. It means that there are good reasons for the processing of your personal information and measures are taken to minimize the impact on your privacy rights and interests. "Legitimate interest" also references our use of your data in ways you would reasonably expect and that have a minimal privacy impact.
A) Provide the Test Result You Request. We use the information we gather about you to calculate your cognitive risk againts Dementia. It is necessary to gather these information to properly calculate the risk. Within the test, no unnecessary personal data will be requested from you except your age, answers, clock drawing photo and optionally email address.
B) Analysis and Development of New Features and Methods. We perform statistical, demographic and UX analyses of users of Cognity, and their answers' patterns, so we can improve our accuracy and minimize false positive/true negative errors.
C) Customizing Your Experience. We use the information that we have to better understand you and customize certain features of the Cognity to provide you with an enhanced experience.
E) Administrative Purposes. We and our service providers use the information we have about you for the following legitimate business purposes:
For auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements;
For fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks; and
To understand and assess satisfaction with Cognity or our customer care team.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest.
G) Aggregating and/or Anonymising Personal Information. We aggregate and/or anonymize personal information so that it will no longer be considered personally identifying. We do so to generate other data for our use, which we may use and disclose for any purpose.
3. With Whom Do We Share The Personal Information We Gather?
B) Sharing With Service Providers. We contract with other companies, agents or contractors (“service providers”) to provide services on our behalf. These services are, for example, cloud computing, credit-card, payment and billing processing, fulfillment of orders, information technology and related infrastructure provision, customer service, ad serving, shipping, email distribution, list processing and analytics, research surveys/interviews/focus group management and analysis, or promotions management. In the course of performing these services, our service providers have access to your information including your personal information.
We may share in aggregate results from research surveys or panels with advertisers.
We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
D) Compliance With Legal Process. We may access, preserve and disclose personal information if we are required to do so by law or we have a good faith belief that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of Cognity; (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions); and (5) cooperate with public and government authorities (which may be outside your country of residence).
4. Other Information Collected Using TechnologyOther information does not specifically identify you and are collected through technology. It includes tracking information collected by us as well as third parties.
Device Information. We collect information about the computer, mobile device or other device you use to access to Cognity, such as Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), geolocation information, unique device identifiers, browser type, browser language and other transactional information.
Analytics, Log Files and Reading History. As is true of most web sites, we gather certain information automatically and store it in log files. This information include IP address , browser type, operating system and other usage information about the use of Cognity, including a history of the pages you view.
We automatically combine this collected log-information with other information we collect about you. We do this to improve services we offer you and provide your test results whenever you demand from us.
One of the analytics service providers we use is Google Analytics. To learn more about how Google use data, visit https://policies.google.com/privacy/partners. For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
Location Information. Some of the test questions need location data to check your answer. If you enable the location-based feature, your current location will be stored locally on your device, which will then be used by the app. If you elect to have a location-based search saved to your history, we will store that information on our servers. If you do not enable the location-based service, or if an app does not have that feature, the app will not transmit to us, and we will not collect or store, location information. The ads in our apps are not targeted to you based on your current GPS location, but they are targeted to you based on your ZIP code or device's IP address.
5. How Do I Opt Out From Receiving Emails?
You can choose not to receive commercial email messages in the future by either (1) following the "unsubscribe" instructions located near the bottom of each email, or (2) you can email us at firstname.lastname@example.org
Email Newsletters. Inoven offers several email newsletters. If you no longer wish to receive a specific newsletter, follow the "unsubscribe" instructions located near the bottom of each newsletter or you can email us at email@example.com
6. How Do I Remove My Personal Information?
If you would like to request to delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at firstname.lastname@example.org
We will respond to your request consistent with applicable law.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
7. Sensitive Personal Information Unless specifically requested (for example, in connection with a particular survey), we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background or trade union membership) through Cognity or otherwise to us. Any requested information that includes sensitive information about political opinions, ethnicity, race, religion, sex life or sexual orientation can be left unanswered.
8. Data Retention
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
9. Is My Information Protected?
We seek to protect personal information with reasonable organizational, technological safeguards commensurate to the sensitivity of the personal information. We use SSL to secure the data flow from mobile client to web service.
10. Children’s Guidelines
We do not knowingly collect or store any personal information from children except as permitted by applicable law.
11. International Transfers
Inoven A.S. is headquartered in Turkey. The information you provide to us or that we obtain as a result of your use of Cognity is collected in your country and subsequently transferred to Turkey or to another country in which we have facilities or our affiliates operate or in which we engage service providers.